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take into account additional amounts which petitioner alleges are
deductible in determining that tax. We hold it should not.
FINDINGS OF FACT
Most facts were stipulated. We incorporate herein by this
reference the parties’ stipulation of facts and the accompanying
exhibits. Petitioner resided in DeLand, Florida, when his
petition was filed with the Court.
Petitioner failed to file timely Federal income tax returns
for 1985, 1986, 1987, and 1988. He filed returns for those years
on various dates in 1999.
On March 15, 1999, respondent issued a Notice of Intent to
Levy and Notice of Your Right to a Hearing to petitioner. On
March 24, 1999, respondent received a properly completed Form
12153, Request for a Collection Due Process Hearing, wherein
petitioner requested a hearing. In a letter dated May 18, 1999,
petitioner informed the Appeals officer that he believed he did
not “need due process” or otherwise need the hearing. The
Appeals officer never conducted a face-to-face meeting or
telephone conference with petitioner.
Respondent issued a Notice of Determination to petitioner on
December 2, 1999. The determination upheld the prior assessments
and proposed levy. In pertinent part, the determination found:
You failed to file your 1985, 1986, 1987, and 1988
Federal individual income tax returns and substitute
returns were prepared by the Atlanta Service Center
based on information obtained from third parties.
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